Estate of Pearl I. Amlie, Deceased, Rodney B. Amlie, Executor - Page 23

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          ultimately received approximately 280 pages of documents.  After            
          reviewing this material, Agent Puntenney had additional                     
          questions, and was referred by Mr. Stille to the estate's                   
          attorney, David Jennett.                                                    
               Mr. Jennett made additional materials available, and after             
          reviewing them Agent Puntenney requested an interview with Rod,             
          as executor of the estate.  Agent Puntenney's request was not               
          satisfied.                                                                  
                                       OPINION                                        
          I.   Burden of Proof                                                        
               The estate contends that the burden of proof with respect to           
          the factual issues in this case has shifted to respondent                   
          pursuant to section 7491(a).  We disagree.                                  
               To be eligible for the burden-shifting benefits of section             
          7491(a), a taxpayer must show that the prerequisites set forth in           
          section 7491(a)(2) have been satisfied.  Allnutt v. Commissioner,           
          T.C. Memo. 2004-239; Oatman v. Commissioner, T.C. Memo. 2004-236;           
          H. Conf. Rept. 105-599, at 239 (1998), 1998-3 C.B. 747, 993.  In            
          particular, section 7491(a)(2)(B) requires taxpayers to cooperate           
          with all reasonable requests by the Commissioner for interviews,            
          documents, and the like.                                                    
               Respondent contends, inter alia, that the estate failed to             
          cooperate because his request to interview Rod was denied.  As              
          our findings indicate, we conclude that Agent Puntenney requested           






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